Marty v. MOHELA

CourtDistrict Court, E.D. Wisconsin
DecidedNovember 21, 2022
Docket2:19-cv-01263
StatusUnknown

This text of Marty v. MOHELA (Marty v. MOHELA) is published on Counsel Stack Legal Research, covering District Court, E.D. Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Marty v. MOHELA, (E.D. Wis. 2022).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

MICHAEL SPIRITFAIR MARTY,

Appellant,

v. Case No. 19-cv-1263-pp

MOHELA, UNITED STATES DEPARTMENT OF EDUCATION, UNIVERSITY OF NORTHERN IOWA and UNI PERKINS LOANS,

Appellees.

ORDER AFFIRMING DECISION OF THE BANKRUPTCY COURT (DKT. NO. 1) AND DISMISSING CASE

Michael Spiritfair Marty, representing himself, filed an appeal from the bankruptcy court’s judgment granting the University Accounting Service, LLC’s and the United States Department of Education’s motions for summary judgment in an adversary proceeding. Dkt. No. 1 at 1. In that proceeding, Marty alleged that his student loans subjected him to undue hardship and asked the court to declare his student loan debt to be dischargeable under 11 U.S.C. §523(a)(8). Marty v. MOHELA, et al., Case No. 18-2187-kmp (E.D. Wis. Bankr.), R. 1.1 The bankruptcy court dismissed the appellant’s claims against all four defendants, see R. 63 at 1, R. 77 at 20, even though two defendants—University

1 The court has cited to the bankruptcy docket in Case No. 18-2187-kmp by using an “R.” for the record cite. Any citation to “Dkt. No.” refers to the docket in this case. of Northern Iowa and UNI Perkins Loan—never responded. The bankruptcy court determined that the outcomes of the plaintiff’s undue hardship claims in the other defendants’ summary judgment motions were dispositive. R. 77 at 20. I. Legal Standard

Federal district courts have jurisdiction to hear appeals from bankruptcy court orders under 28 U.S.C. §158(a). “On appeal, the district court reviews the bankruptcy court’s factual findings for clear error and its legal conclusions de novo.” Paloian v. Grup Serla S.A. de C.V., 433 F.R. 19, 25-26 (N.D. Ill. 2010) (citing Monarch Air Serv., Inc. v. Solow (In re Midway Airlines, Inc.), 383 F.3d 663, 668 (7th Cir. 2004)). “Th[e district] court reviews the bankruptcy court’s evidentiary rulings for an abuse of discretion.” Id. at 46 (citing Alverio v. Sam’s Warehouse Club, 253

F.3d 933, 942 (7th Cir. 2001)). The abuse of discretion standard also governs the denial of a motion for a continuance. In re McGrath, 451 B.R. 817, 822-23 (N.D. Ill. 2011) (citing Matter of Narowetz Mech. Contractors, Inc., 898 F.2d 1306, 1309 (7th Cir. 1990); Herzog v. Leighton Holdings, Ltd., 239 B.R. 497, 503 (N.D. Ill. 1999)). A bankruptcy court abuses its discretion when its decision is “premised on an incorrect legal principle or a clearly erroneous factual finding, or when the record contains no evidence on which the court

rationally could have relied.” Id. (citing In re UAL Corp., 635 F.3d 312, 319 (7th Cir. 2011)). The district court does not ask how it would have ruled, but asks “whether any reasonable person could agree with the [bankruptcy] court.” In re Morris, 223 F.3d 548, 554 (7th Cir. 2000) (quoting Deitchman v. E.R. Squibb & Sons, Inc., 740 F.2d 556, 563 (7th Cir. 1984)). II. Background A. The Bankruptcy Complaint

On August 29, 2018, the plaintiff/debtor, representing himself, filed an adversary complaint in the United States Bankruptcy Court for the Eastern District of Wisconsin. R. 1. The plaintiff sought to discharge his student loans under 11 U.S.C. §523(a)(8). Id. The plaintiff alleged that his student loan creditors were MOHELA [Missouri Higher Education Loan Authority] and University Accounting Service. Id. at ¶9. The plaintiff asserted that the loan debt subjected him to undue hardship. See id. at 3-4. He argued that he had made good-faith efforts to repay his loans for six years before forbearing

payments over the twelve months preceding his complaint. Id. at ¶6. The plaintiff insisted that he “cannot maintain, based on current income and expense, a minimal standard of living if forced to repay the loans.” Id. at ¶10. On October 15, 2018, defendant University Accounting Service, LLC (UAS) answered the complaint and raised affirmative defenses. R. 6. The Department of Education did the same four days later. R. 7. The bankruptcy court held initial pretrial conferences on November 28

and December 12, 2018, during which the parties and the court sought to sort out the proper parties in the case. See R. 77 at 4 (summarizing the effort). The bankruptcy court concluded that “the Department of Education holds notes on the debtor’s direct student loans and the University of Northern Iowa holds the notes on the debtor’s Perkins loans.” Id. On December 12, 2018, the plaintiff filed an amended complaint. R. 12. The amended complaint changed only one paragraph from the original. It added “United States of America, Department of Education” and “University of Northern Iowa, UNI Perkins Loans” as student

loan creditors. Id. at ¶9. UAS answered the amended complaint and raised affirmative defenses on December 8, 2018. R. 13. B. Summary Judgment Motions On June 21, 2019, UAS filed a motion to dismiss party or, in the alternative, a motion for summary judgment. R. 36. The Department of Education filed a motion for summary judgment that same day. R. 37, 39. 1. University Accounting Service’s Motion UAS sought to dismissal from the adversary as a misjoined party under

Federal Rule of Civil Procedure 21. R. 36 at ¶7. It argued that it was not a real party in interest because the plaintiff did not owe it any debt. Id. at ¶¶8-9. UAS asserted that it was a servicing agent for the Federal Perkins Loans and therefore had no interest in the loans and no authority to litigate the dischargeability of such loans. Id. at ¶¶4-6. Alternatively, UAS argued that it was entitled to summary judgment. Id. at ¶11. The bankruptcy court granted UAS’s motion for summary judgment, R.

63, “because the undisputed facts show that it is not the holder of any of the debtor’s loans,” R. 77. 2. Department of Education’s Motion The Department of Education sought summary judgment under Federal Rule of Bankruptcy Procedure 7033 and Fed. R. Civ. P. 56. R. 37, 39. In its brief, the Department of Education argued that the plaintiff’s student loans did

not impose an undue hardship. R. 38. In support of the motion, the Department of Education filed a statement of facts. R. 40. The plaintiff filed a response to the statement of facts, disputing several. R. 44. The plaintiff did not explain why he disputed the facts he disputed, providing responses such as “Plaintiff disputes this alleged fact.” Below, the court recounts the facts as asserted by the Department of Education. The plaintiff obtained a Bachelor of Arts in liberal studies from Iowa State University in 2007 and a Bachelor of Arts in accounting from the

University of Northern Iowa in 2008. R. 40-1 at ¶¶4-5. In 2010, he obtained a Master of Business Administration (M.B.A.), again from the University of Northern Iowa. Id.

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Marty v. MOHELA, Counsel Stack Legal Research, https://law.counselstack.com/opinion/marty-v-mohela-wied-2022.